Making Sustainability Profitable

RSJ Technical Consulting

What is Japan's Design for the Environment?

Law for the Promotion of Effective Utilization of Resources
Enforcement Order
Ministerial Ordinances

Japan has lead the effort to develop a sustainable society based on the 3Rs of Reduce, Reuse, and Recycle. This approach is known as Design for the Environment (DfE). It focuses on making continuous, incremental changes in the design of products in order to reduce the quantity of resources needed for their manufacture (at the front-end) and make discarded products easier to reuse and recycle (at end-of-life).

DfE extends Japan's successful "total quality improvement" methodology into environmental issues. The starting point of deliberations is what is technologically possible, with manufacturers having more influence in determining the kinds of changes and improvements that are made, and government serving to hold manufacturers accountable to the evolving standards for the industry. This is a different approach from that taken by the European Union.

In April 2001, the Law for the Promotion of Effective Utilization of Resources made DfE mandatory for Japanese manufacturers, retailers, purchasers and consumers. It amended the Resource Recycling Promotion Law of 1991 which had been voluntary. Seven basic categories are regulated by the law:
  Designated resources-saving industries should reduce the quantity of manufacturing by-products they generate
  Designated resources-reutilizing industries should reuse waste products as manufacturing feedstock
  Specified resources-saved products should reduce the volume of discarded products at end-of-life
  Specified resources-reutilized products should be easy to recycle at end-of-life
  Specified labeled products should be easy to recycle for sorted collection because they are labeled
  Specified resources-reconverted products should be recycled at end-of-life through "voluntary" manufacturer take-back programs
  Specified by-products of industry should be be recycled as construction materials
The Enforcement Order lists the industries, products and by-products that must comply with the law and specifies the business size threshold for enforcement (smaller businesses are exempt):
  Table 1: Resources-Saving Industries (there are five)
Pulp, paper and chemical manufacturers should reduce quantity of sludge they produce; iron & steel making and copper smelting manufacturers should reduce quantity of slag; auto manufacturers should reduce waste metal & molding sand
  Table 2: Resources-Reutilizing Industries (there are five)
Paper manufacturers should utilize waste paper as feedstock; PVC manufacturers should utilize used PVC pipes/fittings as feedstock; glass container manufacturers should utilize cullet (broken glass) as feedstock; copy machine manufacturers should reuse certain parts; construction firms should utilize waste soil, concrete lump and asphalt-concrete lump in new construction
  Table 3: Resources-Saved Products (there are nineteen)
Automobiles; PCs, TVs and game machines; refrigerators, stoves, microwaves, washers, dryers and water heaters; office desks, swivel chairs, storage furniture and shelving
Manufacturers should use durable materials & make repairable products to extend product life and use smaller & lighter-weight parts to reduce volume at end-of-life
  Table 4: Resources-Reutilized Products (there are fifty)
Power tools & power supplies, guide & emergency lights, fire & security alarms; automobiles; electrically-driven bicycles & wheelchairs; PCs, printers, copiers, faxes; TVs, video cameras, cordless phones & radios, headphone stereos and game machines; vacuums, battery-powered shavers & toothbrushes and electric toys; blood pressure & infusion instruments, electric therapeutic devices, massagers & bubble generators; refrigerators, stoves, microwaves, washers, dryers, water heaters and unit air conditioners; office desks, swivel chairs, storage furniture and shelving; bathroom units and system kitchens
Manufacturers should use non-toxic materials that are recyclable, reduce number of materials and components, design product for easy disassembly without screws or damaging reusable parts, attach batteries without soldering, and label plastics for recycling
  Table 5: Labeled Products (there are seven)
Sealed storage batteries; PVC construction materials; steel & aluminum cans for beverages & liquors; paper or plastic containers for beverages, soy sauce, liquors, cigarettes, salt and products regulated by METI/industry, MOF/finance, MHLW/health or MAFF/agriculture
Products should be labeled for separate collection recycling
  Table 6: Resources-Reconverted Products (there are two)
Sealed storage batteries; PCs & monitors 
Manufacturers should voluntarily take-back and process used products to obtain reusable parts & recyclable materials
  Table 7: Specified By-Products (there are two)
Power plants should process coal ash for use in mortar/concrete; construction firms should classify & store waste soil for use at other construction sites; construction firms should prepare & transport concrete lump, asphalt-concrete lump and scrap lumber for processing at a recycling facility
  Table 8: Resources-Reconverted Products
(these twenty-nine products use sealed storage batteries)
Power tools & power supplies, guide & emergency lights, fire & security alarms; electrically-driven bicycles & wheelchairs; PCs, printers, faxes; TVs, video cameras, cordless phones & radios and headphone stereos; vacuums, electric shavers & toothbrushes and electric toys; blood pressure & infusion instruments, electric therapeutic devices, massagers & bubble generators
Manufacturers should voluntarily take-back used sealed storage batteries and deliver them to the battery manufacturer for processing
There are approximately sixty-two Ministerial Ordinances addressed to the manufacturers of specific products. Numbering of the ordinances is irregular because many are issued jointly by government ministries: METI/industry, MLIT/transport, MAFF/agriculture, MOF/finance, MHLW/health and ENV/environment.
Each ordinance sets forth the judgment criteria or DfE requirements for a single category: resources-saved, resources-reutilized, resources-reconverted, etc. A single product may be regulated by multiple ordinances. For example:
  Autos have DfE requirements as resource-saving industries to reduce waste metal/molding sand in manufacturing, as resources-saved products to extend product life/reduce product volume, and as resources-reutilized products to make the product easier to recycle at end-of-life
  TVs, microwaves, refrigerators, washers, dryers & A/C units have DfE requirements as resources-saved products to extend product life/ reduce product volume, and as resources-reutilized products to make the product easier to recycle at end-of-life
  PCs have DfE requirements as resources-saved products to extend product life/reduce product volume, as resources-reutilized products to make the product easier to recycle at end-of-life, and as resources-reconverted products to provide manufacturer take-back /processing of used products
  Copiers have DfE requirements as resources-reutilizing industries to reuse certain parts in manufacturing, and as resources-reutilized products to make the product easier to recycle at end-of-life
  Sealed storage batteries have DfE requirements as labeled products to carry the designated logo, and as resources-reconverted products to provide manufacturer take-back/processing of used batteries
  Products using sealed storage batteries have DfE requirements as as resources-reutilized products to make batteries easier to remove for recycling, and as resources-reconverted products to take-back used batteries for processing by the battery manufacturer
Japan RoHS was instituted In April 2006 when the Ministerial Ordinances were amended to require labeling of six hazardous substances in seven products covered by EU RoHS and to extend DfE requirements to the importers of these products.

The framework for implementation is provided in the Law:

  Judgment Criteria: relevant government minister issues specific DfE objectives for designated industries/products in a Ministerial Ordinance
  Plan: manufacturer outlines past performance on the criteria, proposed changes being made to improve performance, and expected benefits of the change
  Advice: government minister issues written opinion to manufacturer whose plan is "substantially insufficient"
  Announcement: government minister publishes name of manufacturer that fails to follow "advice"
  Appeal: relevant industry council issues opinion as to whether manufacturer has a justifiable reason for not following advice
  Directive: government minister orders manufacturer to follow advice
  Inspection: government minister makes on-the-spot inspection of manufacturer's facilities/books/papers or requires manufacturer to submit additional information
  Fine: ¥500,000 (about $5,575) for disobeying directive
        ¥200,000 (about $2,230) for failing to submit a plan or report

The Minister of Economy, Trade and Industry (METI) has jurisdiction over electrical & electronic products and automobiles. The Industrial Structure Council handles business entity appeals for METI.

This summary of Design for Environment (DfE) in Japan is designed to provide you with an accurate, easy-to-understand overview of the topic and does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

Back to Tutorial Index

Copyright © 2009 -- All Rights Reserved
RSJ Technical Consulting
PO Box 867705, Plano, Texas 75086